Juan Ramon L.C. v. M. Wofford, Warden of Mesa Verde Detention Facility, et al.

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA

JUAN RAMON L.C., Civil No. 1:26-cv-03958-MWJS ORDER GRANTING PETITION FOR Petitioner, WRIT OF HABEAS CORPUS IN PART

vs. A# 220-938-005

M. WOFFORD, Warden of Mesa Verde Detention Facility, et al.,

Respondents.

ORDER GRANTING PETITION FOR WRIT OF HABEAS CORPUS IN PART Petitioner Juan Ramon L.C.1 entered the United States without inspection approximately six years ago and has resided in the country ever since. Dkt. No. 1; Dkt. No. 6-1, at pg. 3. During his time in the United States, he has developed a substantial criminal record, which includes a December 2025 conviction for “Infliction of Corporal Injury of a spouse/cohabitant” in violation of California Penal Code § 273.5(a). Dkt. No. 6-2. Petitioner was sentenced to serve 100 days in jail pursuant to that conviction, and upon his release from custody in January 2026, ICE arrested him; he has been detained

1 For reasons previously explained in Sergio D.L.S. v. Warden, Cal. City Correctional Ctr., No. 1:26-cv-02821-MWJS, 2026 WL 1049713, at *1 n.1 (E.D. Cal. Apr. 17, 2026), only Petitioner’s first name and the initials of his last name are used in this order. ever since. At no point since his detention began has he been given a bond hearing to challenge the basis for his detention.

Petitioner now invokes this court’s habeas jurisdiction. In a petition for writ of habeas corpus under 28 U.S.C. § 2241, Dkt. No. 1, he contends that his detention without a bond hearing violates the Immigration and Nationality Act (INA). Although

Petitioner does not directly contend that he is a member of the “Bond Eligible Class” certified in Maldonado Bautista v. Santacruz, 813 F. Supp. 3d 1084 (C.D. Cal. 2025), he argues that the district court’s decision in that case was “based on sound law” and that

its “rationale [should be] applied to this case.” Dkt. No. 1, at pg. 3. In Maldonado Bautista, the court certified a class of “[a]ll noncitizens in the United States without lawful status who (1) have entered or will enter the United States without inspection; (2) were not or will not be apprehended upon arrival; and (3) are

not or will not be subject to detention under 8 U.S.C. § 1226(c), § 1225(b)(1), or § 1231 at the time the Department of Homeland Security makes an initial custody determination.” 813 F. Supp. 3d at 1127. And a declaratory judgment was

subsequently entered by that court declaring that all Bond Eligible Class members “are detained under 8 U.S.C. § 1226(a) and are not subject to mandatory detention under § 1225(b)(2)” and accordingly “are entitled to consideration for release on bond by immigration officers and, if not released, a custody redetermination hearing before an

immigration judge.” Maldonado Bautista v. Noem, No. 5:25-cv-01873, 2025 WL 3678485 (C.D. Cal. Dec. 18, 2025). Petitioner contends that the same reasoning employed by the Maldonado Bautista court is applicable to his case.

The court issued an Order to Show Cause, calling on Respondents to address two issues: (1) whether Respondents disputed Petitioner’s apparent membership in the Bond Eligible Class certified in Maldonado Bautista, and (2) whether, regardless of

Petitioner’s membership in the Bond Eligible Class, “any factual or legal issues in this case that render it distinguishable from prior orders” in similar cases where the petition was instead resolved on “statutory grounds under the INA.” Dkt. No. 5. See, e.g., Henry

A.V.L. v. Warden of the Cent. Valley Annex Detention Facility, No. 1:26-cv-3354, 2026 WL 1391273 (E.D. Cal. May 18, 2026); Galvan v. Noem, No. 1:25-cv-1766, 2026 WL 183724 (E.D. Cal. Jan. 23, 2026), report and recommendation adopted, Dkt. No. 14; Avalos v. Chestnut, No. 1:26-cv-1199, 2026 WL 654448 (E.D. Cal. Mar. 9, 2026), report and

recommendation adopted, 2026 WL 825717 (E.D. Cal. Mar. 25, 2026). Respondents timely responded to the court’s order. Dkt. No. 6. In their response, they candidly acknowledge that Petitioner’s case here “mirrors that [of the]

petitioner in Galvan.” Dkt. No. 6, at pgs. 1-2. But they also contend that there is a reason to distinguish Galvan and the other cases cited in the court’s order: in this case, Respondents argue, Petitioner is “subject to mandatory detention under 8 U.S.C.

§ 1226(c)(1)(E),” rendering him ineligible for a bond hearing under the INA and excluding him from membership in the Maldonado Bautista Bond Eligible Class. Id. at pg. 2.

Respondents argue that Petitioner is subject to mandatory detention under § 1226(c) because his December 2025 conviction for “Infliction of Corporal Injury of a spouse/cohabitant” in violation of California Penal Code § 273.5(a) is a “crime involving

moral turpitude,” or “CIMT.” Dkt. No. 6, at pg. 3. Respondents are correct that the INA mandates the detention of any noncitizen “convicted of . . . a crime involving moral turpitude.” 8 U.S.C. §§ 1182(a)(2)(A)(i), 1226(c)(1)(A). Their contention that a

conviction for violating California Penal Code § 273.5(a) is necessarily such a crime, however, is not persuasive. Respondents’ only support for this argument comes from Morales-Garcia v. Holder, 567 F.3d 1058 (9th Cir. 2009), which they cite for the proposition that “Cal. Penal Code § 273.5 . . . is categorically a crime involving moral turpitude

within the meaning of § 1182(a)(2)(A)(i)(I).” Dkt. No. 6, at pg. 3. But Morales-Garcia reached the exact opposite conclusion. See Morales-Garcia, 567 F.3d at 1067 (“We hold that Morales' conviction under Cal. Penal Code § 273.5(a) for abuse of a cohabitant is not

categorically a CIMT within the meaning of 8 U.S.C. § 1182(a)(2)(A)(i)(I) and § 1229b(b)(1)(C).” (emphasis added)); see also Valdez v. Garland, 28 F.4th 72, 77 (9th Cir. 2022) (discussing the holding of Morales-Garcia). Although a conviction under California Penal Code § 273.5 may “sometimes be a CIMT” in certain factual

circumstances, see Carillo v. Holder, 781 F.3d 1155, 1159-60 (9th Cir. 2015), the court cannot conclude on the record before it that Petitioner’s conviction amounts to a crime involving moral turpitude. And because nothing in the record or in the government’s

briefing provides any other reason to conclude that Petitioner is subject to mandatory detention under § 1226(c), the court agrees with Respondents that this case is most akin to cases like Galvan, in which the court granted bond hearings pursuant to § 1226(a) in

order to remedy petitioners’ detention in violation of the INA. Accordingly, given the lack of any factual or legal issues in this case that would distinguish it from the prior orders that this court has found persuasive, IT IS HEREBY

ORDERED that the petition for writ of habeas corpus is GRANTED in part, to the extent Petitioner contends that he is entitled by statute to a bond hearing. Respondents are ENJOINED AND RESTRAINED from continuing to detain Petitioner unless they demonstrate, within seven days of the date of this order, that Petitioner has received a

bond hearing before a neutral decisionmaker in accordance with 8 U.S.C. § 1226(a) and its implementing regulations. Respondents shall file a status report within ten days of the date of this order, confirming whether a bond hearing has been held and, if so, the

outcome of that hearing. /// /// /// The Clerk of Court is directed to close this case and enter judgment for Petitioner. IT IS SO ORDERED. DATED: June 3, 2026, at Honolulu, Hawai’‘i.

a a Ry Te □□ @ /s/ Micah W.J. Smith □ Ee ee Micah Smith United States District Judge ea

Civil No. 1:26-cv-03958-MWJS; Juan Ramon L.C. v. M. Wofford, et al.; ORDER GRANTING PETITION FOR WRIT OF HABEAS CORPUS IN PART